Effective September 11, 2026

MOMENTUM FI Toolkit Privacy Policy

This policy describes the Toolkit’s approved operational privacy baseline. Qualified legal review remains in progress; publication is not a certification of legal compliance.

This Privacy Policy explains how Newton Momentum FI LLC (“MOMENTUM,” “we,” “us,” or “our”) collects, uses, discloses, and retains personal information when you use the MOMENTUM Financial Independence Toolkit at app.momentumficommunity.com. The Toolkit’s educational-use and professional-advice boundaries are described in the general disclaimer.

This policy applies to the Toolkit’s assessments, planning, collaboration, saved-result, document, and email features. It does not govern the separate MOMENTUM community, Harlan Landes’s website, or other linked services.

Data minimization

Ordinary Toolkit questions do not ask for Social Security numbers, financial-account credentials, full account numbers, dates of birth, exact street addresses, or government or student identification numbers. Please do not put those details in notes, nicknames, free-text fields, or uploads unless a feature expressly requires them.

The Toolkit does store personal information needed to provide the service. This can include an email address, optional profile name, device and session information, saved answers and results, and information you choose to provide about professionals, students, properties, or household members. Financial inputs can be sensitive personal information under applicable law.

Information we collect

Accounts and sign-in

We store your email address, email-verification and account status, account timestamps, optional profile settings, email preferences, and newsletter-choice records. Passwordless sign-in records include a hashed token, expiration and use timestamps, and a keyed hash of the requesting IP address. The readable token is not stored in the Toolkit database.

Tool answers, drafts, and results

We collect the answers and assumptions you enter for the tools you use. Saved work can include drafts, completed results, result versions, and the inputs needed to reproduce an earlier result. A saved result can remain after you revise a current draft so history is not silently overwritten.

Some tools let you enter information about advisers or other professionals. Only enter another person’s information when you have authority and a lawful reason to do so.

College Aid documents

Where document assistance is available, an authorized adult may upload a supported financial-aid document for local processing. The Toolkit suggests structured facts for your review; it does not apply them automatically. Remove unnecessary names, addresses, identification numbers, account information, and other details before upload. Do not rely on automated filtering as a substitute for checking the document.

Household invitations and sharing

The Household Alignment feature uses an invitee’s email address to deliver and verify an invitation. Pending display addresses are encrypted and cleared after acceptance, revocation, replacement, delivery failure, or expiration, subject to scheduled cleanup. After joining, participants can see each other’s Toolkit email address to identify the comparison. Draft answers remain private until each participant expressly authorizes a release. Both participants can access the resulting shared analysis.

Technical, usage, and communication information

We receive information needed to deliver and secure the service, such as session and guest-browser identifiers, IP address, browser or device information, requested pages, timestamps, and security or error information. Limited first-party product events can record an assessment start or completion, a question identifier, a download, or a selected next action. Financial answers and result contents are not intentionally copied into analytics metadata.

If you contact us, we collect the information in your message. Postmark delivers operational email. Newsletter enrollment is separate from authentication: if you affirmatively choose the newsletter, your confirmed email address—and not your tool answers or results—is sent to Kit for confirmation.

How we use information

We use personal information to authenticate users; calculate, save, display, compare, download, revise, and delete requested work; preserve result history; deliver authorized invitations and communications; process an optional newsletter request; diagnose failures and prevent abuse; measure aggregate product use; comply with law; and protect legal rights. We may use information that has been aggregated or de-identified so it cannot reasonably identify you.

Cookies and similar technologies

The Toolkit uses essential first-party cookies and comparable browser storage for sign-in, request protection, guest work, and core preferences. We do not use third-party advertising pixels, sell browsing profiles, or use tool answers for targeted advertising. A YouTube or Vimeo player can receive ordinary device and request information only when you choose to load it, under that provider’s policy.

When we disclose information

We disclose information only as reasonably necessary to operate the service or at your direction. Current categories include DigitalOcean for hosting and managed database recovery; Postmark for transactional email; Kit for an optional newsletter request; Microsoft OneDrive for encrypted recovery-journal archives where configured; YouTube/Google or Vimeo when you load embedded media; the intended Household participant through the feature’s invitation and release controls; and parties involved in a legal, safety, or business-transfer need as permitted by law.

We do not sell personal information or share it for cross-context behavioral advertising. We do not give assessment answers or results to advertisers, data brokers, banks, schools, advisers, Kit, or the MOMENTUM community unless you deliberately direct that disclosure.

Retention

• Account and saved tool data: retained while the account or saved work remains, unless you delete a result, assessment, or account.
• Guest drafts: the guest record and associated drafts expire and are scheduled for deletion after 30 days unless claimed through sign-in.
• Magic-link records: a link works for 15 minutes; used or expired records are scheduled for deletion 30 days after use or expiration.
• Server sessions: expire after the configured inactivity period, currently 120 minutes, and are scheduled for deletion within 24 hours.
• First-party analytics: retained for 13 months.
• Application-managed logs: retained for no longer than 14 days. Provider-controlled build, deployment, security, and service records follow the applicable provider schedule.
• College Aid originals and unreviewed extraction: expire after 30 days and can be deleted sooner. Reviewed facts, limited supporting excerpts, and saved analyses remain until the associated records are deleted.
• Pending Household invitation display addresses: cleared when no longer needed. Invitation codes expire after seven days.
• Managed database recovery: DigitalOcean’s recorded recovery window is seven days.
• Encrypted recovery-journal archives: retained for 14 days after a verified archive round trip.
• Email-delivery and suppression records: retained under the email provider’s configured service schedule. Copies in a recipient’s mailbox are controlled by the recipient and their provider.

Deletion from the active application does not immediately remove copies already downloaded by an authorized person or copies waiting to rotate out of a provider’s recovery systems. A restored database is kept closed while recorded deletion and withdrawal actions are reapplied. Provider schedules outside MOMENTUM’s application control are not immediate-erasure guarantees.

Your choices and controls

Signed-in users can view saved work, delete an individual result while keeping assessment answers, delete an assessment and its related results, and delete the Toolkit account and active Toolkit data. Account deletion removes associated plans, saved tool data, login links, active sessions, claimed guest records, and user-linked analytics. Separate records held by Kit, the MOMENTUM community, email providers, or downloaded files are not automatically deleted.

Household withdrawal removes the withdrawing participant’s answers and the shared analysis and decisions for both participants while preserving the other participant’s private draft for a new consent cycle. Archiving is reversible and is not deletion.

Depending on where you live, applicable law may provide rights to request access, correction, deletion, portability, information about disclosures, or an appeal. Contact us to exercise an applicable right. We may need to verify your request.

Security

Safeguards include authenticated ownership checks, limited administrator access, encrypted network connections, secure cookies, hashed access tokens, application encryption for designated sensitive records and documents, private document access, bounded processing, and recovery controls. No online system is completely secure. Protect access to your email account and device because email controls access to your Toolkit account.

Age eligibility and information about minors

The Toolkit is intended only for people age 18 and older. A person under 18 may not create or use a Toolkit account. An authorized adult may provide information about a minor where a college-planning feature permits it. If you believe a person under 18 provided personal information directly, contact us so we can review and delete it as appropriate.

United States operation and international availability

The Toolkit is operated from the United States and primarily directed to U.S. consumers, but access is not limited to the United States. Its educational explanations and examples principally use a U.S. context and may not reflect another country’s laws, taxes, benefits, or financial systems. Information can be processed in the United States and other countries where service providers operate.

Changes to this policy

We may update this policy as the Toolkit, vendors, or legal requirements change. We will post a revised effective date and provide additional notice when required or when a change materially affects how previously collected information is used.

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